A reconciliation entry lets you correct flagged elements of an entry after the goods have cleared, under 19 USC 1484(b). File the entry summary with your best available information, then reconcile within 21 months of the declaration, and one reconciliation entry can cover up to 9,999 underlying entries.
The problem reconciliation solves
Some entry elements are not final when the goods arrive. The value depends on a royalty that settles quarterly. The classification depends on a ruling that has not come back yet. The assists, the tooling the supplier provided free, get valued after the fact. The importer has two choices: hold the shipment until everything is certain, or file with the best available information and fix it later. Reconciliation is the mechanism for the second choice, and it exists because the first choice would stop trade.
Under 19 USC 1484(b), the importer may elect to file a reconciliation for flagged entry elements. The entry summary goes in with the best information available, the elements are flagged as reconcilable, and the correction comes later. It is not a loophole, it is the statute's answer to the fact that trade moves faster than paperwork.
The 21-month clock, and the shorter ones
The reconciliation is due within 21 months of the declaration, which is the general rule. Two categories run shorter. Free trade agreement claims under 1520(d) get 12 months. Antidumping and countervailing duty cases get 90 days after the review period ends. The clocks are different because the risks are different: an FTA claim is a paperwork correction, and an AD/CVD case is a moving duty rate that has to settle before the final number can be known.
The 21 months is generous, and it is also a trap. An importer who flags elements for reconciliation and then forgets about them will find the deadline has passed, and the best-available-information filing has become the final filing. Put the reconciliation dates on the same calendar as the entry dates, or the mechanism will not be there when you need it.
One entry, 9,999 corrections
One reconciliation entry can cover up to 9,999 underlying entry summaries, which is the scale that makes the mechanism useful for a real importer. A company filing a hundred entries a month does not file a hundred reconciliations. It files one, covering the flagged elements across all of them, and the correction lands as a single adjustment.
The scale is also the risk. A single reconciliation entry with an error in it propagates that error across every underlying entry. The reconciliation has to be checked the same way the entries were, because the volume that makes it efficient also makes a mistake expensive.
The bond rider you need first
Reconciliation requires a continuous bond plus a Reconciliation Bond Rider. The rider is a separate undertaking, and without it, CBP will not accept the reconciliation. Importers who file on a single-entry bond, or on a continuous bond without the rider, find out at the worst moment: when the reconciliation is due and the bond does not cover it.
The rider is cheap and the failure is expensive. Get the rider when the continuous bond is set up, not when the first reconciliation is due. And note the limit: no drawback is available on additional amounts tendered under a reconciliation, so the reconciliation is a correction, not a refund mechanism.
Keep reading
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Frequently asked questions
What is a reconciliation entry?
A filing under 19 USC 1484(b) that corrects flagged elements of an entry after the goods have cleared. You file the entry summary with your best available information, flag the uncertain elements, and reconcile them later.
How long do I have to file a reconciliation?
Within 21 months of the declaration, generally. Free trade agreement claims under 1520(d) get 12 months, and AD/CVD cases get 90 days after the review period ends.
How many entries can one reconciliation cover?
Up to 9,999 underlying entry summaries. That scale makes reconciliation practical for importers filing hundreds of entries, but it also means an error in the reconciliation propagates across every entry it covers.
Do I need a special bond for reconciliation?
Yes. Reconciliation requires a continuous bond plus a Reconciliation Bond Rider. Without the rider, CBP will not accept the reconciliation, so get it when the bond is set up, not when the filing is due.